Public-domain · open source
OpenJurist

2006 S.D. 27

Hoaas v. Griffiths

South Dakota Supreme Court

Decided March 22, 2006

South Dakota Supreme Court · decided 2006-03-22

Relies on Dacy v. Gors

Good law ✅— No negative treatment on recordhow we know

Decided 2006-03-22

How this case has been cited

Cited by 10 later decisions — most recently September 2020

1 district · 9 state decisions

50200620102020decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

View the full empirical analysis of this case →

SABERS, Justice

¶1(concurring specially).

¶2[¶27.] I concur specially to point out that, in my opinion, the trial court ignored two time honored principles that rose from these facts.

¶3[¶28.] The basic facts are that Hoaas stole or misappropriated $68,850 from the corporation and Griffiths and they withheld $58,447 to offset the loss. This conduct was understandable, especially considering the principle that “possession is nine tenths of the law.” Why deliver to a thief or misappropriator money you claim he owes you? Accordingly, the grant of summary judgment by the trial court was premature, if not wrong. The jury should have determined under proper instructions whether it was proper to offset the amount taken.

¶4[¶ 29.] The second time honored principle is that a “person cannot profit from [one’s] own wrong.” Dacy v. Gors, 471 N.W.2d 576, 581 (S.D.1991) (Sabers, J„ dissenting). This principle supports our decision today that Hoaas should not recover a judgment, punitive damages, or costs.

/2006/sd/27 · .json · Public domain